Siros, Stephen William
PD-0941-15
Tex.Sep 25, 2015Background
- Victim Isaias Valdez was shot and killed on I‑45 on July 17, 2009; police later tied the fatal shot to a high‑powered rifle (something like an AR‑15).
- Officers surveilled an apartment used by Jonathan Siros and associates; execution of a search warrant recovered two AR‑15 rifles, one purchased by appellant Stephen Siros.
- Witness Juan Figueredo (a federal arrestee and cooperating witness) implicated Stephen: Figueredo testified that Stephen drove a van that enabled Christopher Garcia to shoot the victim and later boasted about facilitating the shot; Figueredo also testified about payment to Stephen after the killing.
- Stephen gave a videotaped statement claiming he was driving but was surprised when Garcia produced the rifle and shot the victim.
- Stephen was indicted for capital murder (alleging remuneration); the jury convicted him of the lesser included offense of murder and sentenced him to 36 years. The First Court of Appeals affirmed; Stephen filed a petition for discretionary review raising eight issues.
Issues
| Issue | Plaintiff's Argument (Siros) | Defendant's Argument (State / Appellate Court) | Held |
|---|---|---|---|
| Sufficiency of evidence to convict as a party | Evidence insufficient: Siros claims he was unaware Garcia would shoot; appellate court applied Jackson standard incorrectly and factual sufficiency should be considered | Evidence (Figueredo’s testimony, Siros’s bragging, Siros driving the van, possession/purchase of AR‑15) cumulatively supports party liability under §7.02 | Affirmed: Court applied Jackson standard and held evidence sufficient to support murder conviction as a party |
| Corroboration of accomplice (Art. 38.14) | Figueredo is an accomplice; his testimony lacks independent corroboration tying Siros to murder | Non‑accomplice evidence (Siros driving, recovery of AR‑15 bought by Siros, statements at club) tends to connect Siros to the offense; defer to jury when evidence conflicts | Affirmed: cumulative non‑accomplice evidence sufficiently corroborated Figueredo’s testimony |
| Accomplice‑witness instruction (whether Figueredo was accomplice as matter of law) | Trial court should have instructed jury that Figueredo was accomplice as a matter of law | Evidence was conflicting on Figueredo’s culpability; whether he was an accomplice was a fact question for the jury | Affirmed: trial court did not abuse discretion by submitting accomplice status to jury as fact question |
| Jury charge permitting conviction as principal actor | Charge allowed conviction as principal though evidence showed Garcia was shooter; this could lead to non‑unanimous or irrational verdict | State argued it prosecuted the party theory; any charge error was harmless because evidence overwhelmingly supported party liability and prosecutor argued party theory | Affirmed: even assuming error, any harm was non‑egregious and harmless under Almanza factors |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes standard for legal sufficiency review)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App.) (discusses single sufficiency standard and appellate review approach)
- Winfrey v. State, 393 S.W.3d 763 (Tex. Crim. App.) (applies Jackson standard)
- Smith v. State, 332 S.W.3d 425 (Tex. Crim. App.) (accomplice‑witness instruction and corroboration principles)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App.) (cumulative circumstantial evidence standard)
- Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App.) (harm analysis for jury‑charge error)
- Amador v. State, 221 S.W.3d 666 (Tex. Crim. App.) (standard for reviewing suppression rulings; bifurcated review)